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PLc Auditee Facility Audit Guidelines Oct2005

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PrimusLabs.com Auditee Facility Audit Guidelines A Guide for Auditees Preparing for PrimusLabs.com Audits October 2004 Rev 3 For use in conjunction with V03.02 Audits V3.02 Rev 3 PrimusLabs.com Facility Audit Guidelines Page 1 PrimusLabs.com Facility Audit Guidelines The document is for guidance only and in no way replaces any Regulatory Legislation or Guidance. The PrimusLabs.com Facility Audit Guidelines are not exhaustive and detail minimum requirements only by means of short statements related to audit questions. There will be variations in applicability to an operation based on the process(es) and commodities involved. PrimusLabs.com accepts no liability for the contents of this document, nor how an individual chooses to apply this document. This document has been developed to enable facilities to evaluate the food safety risks of storing, processing and/or packing food within their operation. They are intended to help management identify preventative programs that need to be in place and to identify problems that may currently exist. Used in combination with our self-audit program www.primuslabs.com/fs/self.html a facility can evaluate their food safety programs and prepare for a Third Party Audit. The expectations are based on the V03 Processing Audit and therefore some specific expectations may not be applicable to all operations e.g. packinghouses, cooling/cold storage ...
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 PrimusLabs.com 
     Auditee Facility Audit Guidelines                   
A Guide for Auditees Preparing for PrimusLabs.com Audits
     October 2004 Rev 3  For use in conjunction with V03.02 Audits
V3.02 Rev 3 PrimusLabs.com Facility Audit Guidelines
Page 1
PrimusLabs.com Facility Audit Guidelines  The document is for guidance only and in no way replaces any Regulatory Legislation or Guidance. The PrimusLabs.com Facility Audit Guidelines are not exhaustive and detail minimum requirements only by means of short statements related to audit questions. There will be variations in applicability to an operation based on the process(es) and commodities involved. PrimusLabs.com accepts no liability for the contents of this document, nor how an individual chooses to apply this document.  This document has been developed to enable facilities to evaluate the food safety risks of storing, processing and/or packing food within their operation. They are intended to help management identify preventative programs that need to be in place and to identify problems that may currently exist.  Used in combination with our self-audit programwww.primuslabs.com/fs/self.htmla facility can evaluate their food safety programs and prepare for a Third Party Audit.  The expectations are based on the V03 Processing Audit and therefore some specific expectations may not be applicable to all operations e.g. packinghouses, cooling/cold storage operations, storage and distribution facilities. An explanation of deviations from processing operations will be given where possible but it is ultimately the responsibility of the user to determine whether an expectation is applicable to their operation or not.system in this manual is also based on theThe numbering V03 Processing Audit with HACCP Template –the other facility audits (Packinghouse, Cooler etc.) have less of the same questions.  The expectations are based on: FDA “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables” http://vm.cfsan.fda.gov/%7Edms/prodguid.html%20 Current Good Manufacturing Practices (GMPs) regulations 21 CFR 100-169 http://cm.cfsan.fda.gov/%7Elrd/part110t.txt  Food Code, 2001 edition (FDA/USPHIS)http://vm.cfsan.fda.gov/%7Edms/fc01-toc.ht  Food Producers, Processors, Transporters, and Retailers: Food Security Preventive Measures Guidanceiu.desgcthlm.dcaf.sg/a/nv.mfdtmtsp/:ov/h~  Guidance on Inspection of Firms Producing Food Products Susceptible to Contamination with Allergenic IngredientsIny_rgleAls/igf/er_tcepsni/aro/va.gow.fd//wwttp:htmG_iuedh.psceitno  Guidelines for Interim Country of Origin Labelinghttp://www.ams.usda.gov/COOL/  Buyer specifications and requirements.  
V3.02 Rev 3
PrimusLabs.com Facility Audit Guidelines
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Audit Format and Scoring Guidelines  There are currently 6 Facility Audit Formats. All have at least 2 sections, the GMP Section (Facility Tour) and the Food Safety File Section (Paperwork). Some have HACCP sections added. All audits now have food security and miscellaneous sections – these questions are for information only at this time, i.e. they are not scored.  Cooler and Cold Storage Audit. This audit is designed to be used for facilities that are receiving goods directly from the fields, orchards etc. after harvest. If there is any packing, repacking, grading etc. occurring on site, then a Packinghouse Audit should be used.  Packinghouse Audit. This audit should be used for any operation that is grading, packing, repacking, washing whole produce etc. If the item is being sliced, shredded, dried, juiced etc., then a Processing Audit should be used.  Packinghouse with HACCP Audit.  Many buyers are requesting facilities to create and maintain HACCP Systems for their products. PrimusLabs.com offers both it’s Packinghouse and Processing Audits with a HACCP Audit section added onto the standard version.  Processing Audit.  This audit should be used for any operation that is washing and slicing, shredding, drying, juicing etc. any item i.e. any "further processed" items.  Processing with HACCP Audit.  Many buyers are requesting facilities to create and maintain HACCP Systems for their products. PrimusLabs.com offers both it’s Packinghouse and Processing Audits with a HACCP Audit section added onto the standard version.  Storage and Distribution. This audit is designed to be used on facilities that are receiving and storing finished goods e.g. regional distribution warehouses. If there is any packing, repacking, grading etc. occurring on site, then a Packinghouse Audit should be used.
            
V3.02 Rev 3
PrimusLabs.com Facility Audit Guidelines
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 The audit format is updated as needed. This may include the layout, the questions themselves and point assignments. The following is the scoring system used for the PrimusLabs.com facility audits: PRIMUSLAB.COMSCORESYSTEM FORENTIREAUDIT Percentage (%) Category 95-100 Superior 90-94 Excellent 85-89 Good 80-84 Standard < 80 Unsatisfactory
 POINTSYSTEM FORINDIVIDUALQUESTIONS Possible Question Full Minor Major Non-Points Compliance Deficiency Deficiency compliance 15 Point Question 15 points 10 points 5 points 0 points 10 Point Question 10 points 7 points 3 points 0 points 5 Point Question 5 points 3 points 1 point 0 points 3 Point Question 3 points 2 points 1 point 0 points  
COMPLIANCECATEGORIES FullTo be in full compliance of appropriate GMPs, sanitation, pest control, Compliancedocumentation and/or HACCP requirements. MinorTo have minor deficiencies of appropriate GMPs, sanitation, pest control, DeficiencyHACCP requirements. There is little potential hazard todocumentation and/or product. Majorof appropriate GMPs, sanitation, pest control,To have major deficiencies Deficiencydocumentation and/or HACCP requirements. Potential hazard to product exists. Non-To have serious deficiencies of appropriate GMPs, sanitation, pest control, compliancedocumentation and/or HACCP requirements. Actual hazard to product exists.    
V3.02 Rev 3 PrimusLabs.com Facility Audit Guidelines
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Facility Audit Agenda   Audit agenda’s do vary, but the normal pattern of events is as follows:  Meeting. Confirm the appointment details, introduce the auditor(s) and auditeeOpening contacts, get some background and history of the operation. Confirm day’s agenda.  Tour of Operations– areas depend of the type of facility, but might include raw material storage areas, production, finished goods storage, personnel facilities, maintenance, chemical storage, packaging storage and external areas e.g. where dumpsters are located.  Food Safety File(paperwork section). New auditees must have at least three months worth of paperwork available (unless a short season crop packing facility).  HACCP Section (if relevant).The auditor might look at the HACCP file in the opening meeting in order to orientate themselves about the site program and CCP’s.  Food Security Section.The auditor will have made notes about physical security aspects when carrying out the tour of the operation. This area is scored, but is a separate total percentage from the rest of the rest of the audit.  Miscellaneous Questions.V3.02 questions include Employing Minors, Country Of Origin Labeling and Allergens. These questions are not scored.  time. Sometimes needed to collate notes before delivering the closingAuditor "quiet" meeting.  Discuss non-compliance points with the auditee team. Please note thatClosing Meeting. PrimusLabs.com auditors are not able to provide either a final score or pass/fail commentary at the end of the audit due to the high number of questions that are asked in the template and the scoring system that is applied. PrimusLabs.com auditors however do expedite audit reports very quickly and auditees should contact PrimusLabs.com if reports have not been received electronically two weeks after the audit has occurred (at the latest).
 It isimperativethat a normal compliment of personnel are onthat the plant is running product and site when the audit occurs in order for the auditor to complete a valid assessment. If the plant is not running and/or there are no production staff on site, then the audit will have to be terminated and cancellation charges will be applied or the audit can continue as an educational audit. Please ensure that auditee personnel are available to follow the plant tour and are well versed in the areas that are being inspected.    For further information about the facility audit process and booking facility audits please go top.irumlspt/:w/wwht.tidmth/pfsaures.abm/co.         V3.02 Rev 3 PrimusLabs.com Facility Audit Guidelines
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 Good Manufacturing Practices - Section 1
General Food Safety 1.1.1 There shall be a designated person in charge of the facilities food safety programs including verification of sanitation activities. This person should ideally be a manager within the company.  1.1.2 All chemicals shall be stored in a designated (sign posted), dedicated, locked area away from food and packaging materials and separated from processing areas. Access to chemicals shall be controlled, so that only personnel who understand the risks involved and have trained properly are allowed to use these chemicals. All chemicals must have legible labels of contents including chemicals that have been decanted from master containers into smaller containers. Where chemicals are stored, adequate liquid containment techniques need to be employed (secondary containment, absorbent materials, angled sealed floors, spill kits, etc.) Liquid should not be stored above powders. Chemical storage should be designed to help contain spills and leaking containers. Empty containers must be stored and disposed of correctly  1.1.3 Signs indicating proper GMP requirements shall be posted visibly and in the language(s) of the employees (visual signs allowed) in the following areas:  Before entering areas that require hair/beard nets and smocks.  Before areas that prohibit food, tobacco products, chewing gums.  Bathrooms and break-room(s) should have hand-washing signs as reminders to wash hands before returning to work. Pest Control 1.2.1 Products and ingredients must be free from evidence or the presence of insects/rodents/birds.Evidence of contamination constitutes automatic audit failure (in a PrimusLabs.com audit).This would be considered adulteration of a food product or ingredient and violates section 402(a)(3) of the code of federal regulations. See 1.2.3 for reference to potential indications of pest presence.  1.2.2 free from evidence or the presence of insects/rodents/birds.Packaging supplies must be Evidence of contamination constitutes automatic audit failure (in a PrimusLabs.com audit).This would be considered adulteration of a food product or ingredient and violates section 402(a)(3) of the code of federal regulations. See 1.2.3 for reference to potential indications of pest presence.  1.2.3 All areas must be free of reoccurring/existing internal pest activity. Specifically there shall be:  No reoccurring/existing rodent activity and/or bird nesting observed around the interior perimeter or the facility.  No evidence of live animals observed inside the facility such as cats, dogs, deer, etc.  No evidence of excreta/pellets  spiders/webbing, rodents, lizards, ants or birds in theNo evidence of pests including insects, facility.  No evidence of gnawed bags/sacs or rodents on stored stock or numerous excreta on the floor/shelves of any storage area.  No decomposed rodent(s) or other animals (frogs, lizards, etc.) in traps. The interior traps shall be checked often and the dead rodent(s) or other animals removed.  Glue boards shall be free of significant insect build up and/or dust. V3.02 Rev 3 PrimusLabs.com Facility Audit Guidelines Page 6
 1.2.4: All areas shall be free of reoccurring/existing external pest activity. Specifically there shall be:  No reoccurring/existing rodent activity (significant burrows, trails, excreta, tracks), animal spoors and/or bird nesting observed around the exterior perimeter of the facility (within 20 feet or 6 meters).  No decomposed rodent(s) or other animals (frogs, lizards, etc.) in bait stations or along perimeter. Findings of a few “fresh” rodents and/or evidence ofrodents feeding in the external traps is not viewed as a problem.  1.2.5 Pest control devices shall be placed so that there is no threat of contaminating product, packing or raw materials. This includes the following restrictions:  Bait stations must only be used outside the facility.  be used if necessary and must meet all legalIndoor pesticide applications shall only requirements. Applications must carried out by a licensed applicator and fully documented.  Domestic fly sprays (aerosols) shall not be used within production and storage areas.  Pellet or grain bait must not beBlock bait shall be used in bait stations and be properly secured. used  insect light traps shall be regularly cleaned out (kept free from aIf used, electric fly killers or build-up of insects and debris, which has the potential for “spilling over”).   meters) from product, (3insect light traps must be at least 10 feetIf used, electric fly killers or equipment, or packaging material. Electric fly killers or insect light traps shall not be located above dock doors (potential for forklift damage and attracting insects into the facility). Hallways where product passes through are exempt from these distances as long as product does not stop or is not stored in the hallway.  replaced annually (and recorded) preferably in the spring time.If used, insect trap bulbs shall be  Fly swatters shall not be used in production or storage areas.   No bait shall be found outside bait station.  Snaps traps can only be used when monitoring traps e.g. tin traps show that there is a serious problem and eradication steps are required. Snap traps should be checked daily (and recorded). Snap traps should not use allergen containing baits e.g. peanut butter. Snaps traps are only allowed as a short term eradication solution since they present several risks                    
V3.02 Rev 3
PrimusLabs.com Facility Audit Guidelines
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 1.2.6 Pest control devices shall be maintained in a clean and intact condition and marked as monitored on a regular basis.  Ifnon-toxicglue boards are used, they shall be changed frequently ensuring that the surface has a shiny glaze with no build up of dust or debris.  If mechanical wind-up traps are used, they must be wound. Winding is checked by triggering the spring device to operate the trap. The trap must be rewound after testing.  Interiors of traps and bottom of glue boards shall have service labels dated and initialed (unless using a barcode system) after each check by the trained operators.  Traps and bait stationsand initialed (unless using a barcodeshall have service labels dated system) after each check by the licensed PCO.  Bait in bait stations shall be secured inside the bait station on a rod above the floor of the station or the bait station is designed so bait cannot be removed by a rodent or “float away” in heavy rain.  Bait stations shall be tamper resistant.  Bait stations shall not be missing entire bait.  Bait shall not be old or moldy.  Bait stations and traps shall not be fouled with weeds, dirt, and other debris.  Pest control devices should be checked at least monthly (checking more frequently is an ideal situation). Local regulations may exceed the above guidelines. At all times, local regulations must be met.  1.2.7 Interior, exterior of the building perimeter and land perimeter pest control devices shall be adequate in number and location As aguide to number and placement of traps and bait stations: Traps shall be positioned at a maximum of 30 feet (9 meters) around the inside perimeter of all  rooms. If a wall is less than 30 feet (9 meters) long, it shall have at least one device.  Inside the facility, only mechanical traps shall be placed within 6 feet (about 2 meters) of both sides of all outside exit/entry doors. This includes either side of the pedestrian doors. Effort shall be made to avoid placing traps on curbing..  a maximum of 50 feet (15 meters) intervalsBait stations or live traps shall be positioned at around the exterior of the building perimeter and within 6 feet (about 2 meters) of both sides of all outside exit/entry doors, except where there is public access (public access is defined as access easily gained by the general public such as parking lots or sidewalks, school areas or areas of environmental concern).  maximum of 100 feet (30 meters) intervalsBait stations or live traps should be positioned at a along the fencing of the facility property, except where there is a public access.  Outside packaging storage must be protected by an adequate number of pest control devices.  1.2.8 All pest control devices shall be identified by a number or other code (e.g. barcode) and a coding system shall be in place to identify the type of device on a map. All traps shall also be located with a wall sign.  1.2.9 to minimize the movement of the device and be tamperBait stations shall be secured resistant. Bait stations shall be secured with either a ground rod or chain, or glued to the wall/ground, or secured onto patio blocks. If bait stations are secured to patio blocks, then associated wall signs are mandatory. Bait stations must be tamper resistant (screws, latches, locks, etc.). Live traps must be positioned so that the openings are parallel with and closest to, the wall. Efforts shall be made to avoid placing traps on curbing. If used,electric fly killersmust be at least 10 feet (3 meters) from product, equipment or packing material.Electric fly killersshall not be located above doors though which product passes. Hallways where product passes through are
V3.02 Rev 3 PrimusLabs.com Facility Audit Guidelines Page 8
exempt from these distances, as long as product does not stop or is not stored in the hallway (see 1.2.5).  Storage Areas & Packing Materials 1.3.1 All ingredients, products and packaging shall be stored off the ground (i.e. on racks, pallets, shelves, etc.). Materials shall be properly protected during storage to prevent contamination. Ideally, raw materials, finished product and packaging materials should be stored in separate areas to prevent cross contamination. When separate room storage is not possible, it is permissible to store them together, but far enough apart to prevent contact. Raw unprocessed items should not be able to contaminate finished washed/processed items. Packaging storage, especially dust from cardboard storage should not contaminating produce items. If mixed food items are stored on site then there should be controls to prevent contamination issues e.g. raw eggs should not be stored above raw produce, glass items should be kept in a separated area and always stored near ground level. Wet product must not be stored above dry product. Wet product stored in racking must not be allowed to drip onto exposed product underneath.  1.3.2 The storage areas for product and packaging shall be enclosed and pest proof. Main doors should be kept closed unless in use. Food contact packaging should not be stored outside. Non-food packaging e.g. cardboard outers should be stored inside if possible, but if necessary (will result in a minor down score) to store outside (e.g. insufficient space for indoor storage) the packaging must be covered with a waterproof and dust proof shroud and included in the pest control program.  1.3.3 Only food, food contact products and items related to the process shall be stored in the facility main storage areas. Sanitation chemicals and maintenance equipment storage should have their own dedicated storage areas.  1.3.4 All storage racks shall be properly designed for proper drainage of water and to permit air circulation.  1.3.5 Products and raw materials should free from spoilage, adulteration and/or gross contamination. Where legislation exists (e.g. USDA Grading Standards) then contamination should be viewed against this standard. Spoilage or adulteration would include any physical, biological or chemical contamination e.g. glass, trash/litter in products. Adulteration of ice shall not be permitted and water used for ice for product cooling must be potable.Any observation of gross contamination of ingredients, product or product contact surface will qualify as an automatic failure(in a PrimusLabs.com audit).  1.3.6 All products that are being rejected or are awaiting final disposition (on hold) shall be stored in a way that avoids accidental use of these materials in the production process (unless they have been cleared for use). The rejected or on hold items must be tagged as such, with a date showing when the product was placed on hold/rejected and the reason for being on hold/rejected. The tagged product must not be commingled with other goods in such a way that their disposition is not clear. A designated hold area and using disposition logs are commendable practices.  1.3.7 All storage areas shall be clean and well ventilated and protected from condensation, sewage, dust, dirt, toxic chemicals or other contaminants. Ledges and drains (if relevant) shall be clean and free of debris. Products and packaging must be clean and free from dust, debris and out of place materials, etc.  1.3.8 and packaging shall be properly marked with receipt dates and/orAll ingredients, products tracking information (lot numbers, code dating) for traceability and stock rotation.  
V3.02 Rev 3 PrimusLabs.com Facility Audit Guidelines Page 9
1.3.9 All ingredients, products and packaging shall be rotated using FIFO (First In First Out) policy to ensure items are used in the correct order they are received within their allocated shelf life. Commodities that undergo ripening treatments are exempt. Packaging rotation may be affected by market forces.  Operational Practices 1.4.1 generation of condensation, dust or spillage from equipment. LimitedThere shall be no spillage to the floor is permitted provided it is frequently cleaned away and does not result in build-up or potential cross contamination. Fixtures, ducts and pipes shall be installed in a manner that avoids contaminating the product, packaging or equipment.  1.4.2 Process flow, facility layout, employee control and utensil control shall ensure that processed products are not contaminated by raw (unprocessed) products. Raw products should not come into contact with processed products, especially processed products that have been washed, cut or thermally treated. Staff who handle raw products must not then handle processed products without first ensuring that they are free of raw material contaminants. This must include hand washing, glove change etc., but might also include changing into a new set of garments. Ideally staff should be dedicated to handling raw or processed goods, but not both within a shift. Utensils should not be allowed to be vectors for cross contamination; ideally dedicated coded utensils should be provided for raw and processed goods, failing this, there should be a utensil sanitation step between uses. Note that anti-microbial washes are not kill steps, but they are microbial reduction steps.  1.4.3 shall be free from condensation or dust. Ladders orCeilings and/or any overhead fixtures walkways above exposed product or packaging material shall have kick plates at least 3 inches high. Forming condensation (above process, product or packaging) must be wiped before the condensate drips.  1.4.4 provided for proper storage and operation to permit trafficThere shall be sufficient space flow and daily operations without likely cross contamination. In processing plants, the flow should be such that raw product shall not cross contaminate the processed finished product.  1.4.5 Production/packing areas shall be inside the facility i.e. enclosed by walls and roof. Production/packing should also be physically separated from storage areas. In some cases a physical barrier between production/packing and storage areas might be required – this will depend on the type of product being produced and the items being stored.  1.4.6 All re-work shall be handled correctly. Rework includes product that has come directly from the line or perhaps returned from a customer but of good quality. Rework will vary from one product to another. GMPs must be followed and cross contamination issues must be considered when handling rework. Re-work areas in coolers must adhere to all required GMP's. In a cooler where the re-packing is a daily routine event, then a packinghouse audit template should be used Traceback details of the product must be transferred correctly.  1.4.7 Raw ingredients or products shall be examined for damage, insect or rodent infestation, temperature abuse, tampering, etc. before use.  1.4.8 All products shall be appropriately labeled, identified and possess lot numbers and/or code dating information. On bulk product, the coding should be on the on the carton or RPC tag; on bagged, clamshell and other prepacks, the coding should be on the pack itself and also on the cartons.  
V3.02 Rev 3 PrimusLabs.com Facility Audit Guidelines Page 10
1.4.9 in place and where necessary tested to ensureForeign material control method(s) shall be proper operations. The frequency and types of testing shall be established in a written program and the frequency is adhered to by QA personnel and documented. Foreign material controls include detectors, traps, visual, sieves, filters and magnets. Metal detection is a must for products that have been cut, sliced, diced or shredded using an automated cutting machine e.g. an Urschel Slicer. Continuous visual inspection is acceptable for whole products.  1.4.10 The strength of sanitizers (product and cleaning) shall be checked on a regular basis and recorded. Test strips or test kits for checking the concentrations of the sanitizers (dip stations, wash water, etc) should be in use. Solutions that are too weak will be ineffective, while those too strong may be harmful to employees or product. Where necessary, pH of solutions should also be checked.  1.4.11 Hand washing stations shall be located where needed e.g. hand washing stations in restrooms, after dressing/changing rooms/before entering the processing/packing area, inside processing/packing area, etc. Ideally hand-wash stations should be located in full sight in order to observe discipline (especially in ready to eat plants). Enough stations should be provided to ensure efficient staff flow. Hands-free is an optimum system for food establishments.  1.4.12 Bathrooms (toilets, restrooms) shall be adequate in number and convenient in location:  Bathrooms should be located within a reasonable distance from the employees' workstation.  Bathrooms should be readily available to male and female employees.  There should be one toilet for every 20 employees.  Hand wash stations should be clean and functioning.  At least one wash sink or equivalent should be provided for each ten persons up to 100 persons.  able to be locked from inside.Each individual toilet facility must be  maintained, well lighted and ventilated to outside air.Each toilet facility must be  Each individual toilet facility shall occupy a separate compartment with a door and walls sufficient to assure privacy.  In the toilet room, the floor and side walls shall be watertight. sidewalls shall be watertight The to a height of at least five inches.  of all toilet rooms shall be made of a finish thatThe floors, walls, ceiling, partitions and doors can be cleaned easily.  Doors to toilet facilities must not open into areas where food is exposed to airborne contamination, i.e. in processing and packing areas. Double doors or a positive airflow system may be acceptable.  facility, i.e. not located in the amenity areaDoors to restrooms that do open into the production or office area, must be kept closed at all times e.g. a spring loaded door.  Restrooms should be properly stocked with scentless soap, paper towels and toilet rolls.  1.4.13 All hand wash stations should have warm water (>85ºF, 30ºC) available for use within 10 seconds. Warm water is more effective in hand washing because it facilitates the removal of oil and dirt from hands and encourages employee usage.   1.4.14 Hand dip and/or hand gel and/or alcohol spray stations shall be adequate in number, convenient in location and properly maintained. Secondary hand sanitation is required for fresh-cut operations, for operations producing washed ready-to-eat products (e.g. tomatoes) that have edible skins/peels and for unwashed, potentially ready to eat items e.g. blueberries. Hand dips, gels or sprays do not replace hand-washing requirements. Hand dips should contain a USDA approved food grade sanitizer at a determined and regularly monitored concentration  1.4.15 processing areas when crossing into aFoot (boot) stations (foot dip mats) shall be located in “clean” zone from an area of potential contaminatione.g. raw storage to packaging, from bathrooms V3.02 Rev 3 PrimusLabs.com Facility Audit Guidelines Page 11
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